11/13/08 - Clarification of IDHS Child Care Collaboration Program Issues
In June, Bureau staff conducted six (6) training sessions statewide on the Child Care Collaboration Program. A number of issues were raised at these sessions. Please consider this memo the Department's clarification of these issues and proceed
accordingly when implementing this program.
The future of early care & education is in collaboration. The DHS Collaboration Program is the test ground to raise collaboration issues and costs. We will implement this program to the fullest extent the way it is written and within the spirit of
the administrative rule so we can ascertain those issues and costs. All DHS staff and agents will be supportive of this program.
Many of these clarifications refer to current policy. Please note that the DHS Child Care Program Manual is now online. It can be accessed through www.dhs.state.il.us - place your curser
over About DHS and click on Publications in the drop down menu. Next, click on manuals, then Human Capital Development Manuals, then Child Care Program Manual.
- Specifically, how are the traditional "special" cases handled, many of which are often given 3 months of eligibility or "pended?" All families/cases in collaboration slots, once determined eligible, will be granted annual, or 12 months, eligibility.
- Cash Paid (cases where the applicant is paid in cash)
Refer to Policy Number 02.02.01, #4 in the DHS Child Care Manual. This situation will be handled as stated in the policy in both collaboration and non-collaboration Child Care Assistance Program (CCAP) cases, except that after the initial 3 month period
when eligibility is still maintained, collaboration cases will get 12 months of eligibility, not six
- Employment Letter/Initial Employment (cases where the applicant has just started a job and has a letter from his/her employer, but no pay stubs yet)
Refer to Policy Number 01.03.02 in the DHS Child Care Manual. The difference between the policies for non-collaboration cases is that collaboration cases, once determined eligible, will all be entered initially with annual/12 months' eligibility. Due to
audit requirements, applicants must provide pay stubs within 3 months or sooner or be put on a ninety (90) day job search or cancelled. It is up to approved collaboration providers to develop a tickler system for these families so that approximately six
weeks prior to the 3 month deadline, they work with the parents to obtain the needed documentation and ensure it is submitted to CCAP eligibility staff, whether at the CCR&R or at DHS in Springfield.
Refer to Policy Number 01.03.03. in the DHS Child Care Manual. These cases will all be entered with annual/12 months' eligibility. Applicants must still submit class schedules and grades for every semester/quarter to verify that their initial reason for
child care is still valid. If this is not done, the case may be cancelled. It is up to approved collaboration providers to develop a tickler system for these families so that every semester/quarter beginning and end, they work with the parents to obtain
the needed documentation and ensure it is submitted to CCAP eligibility staff, whether at the CCR&R or at DHS in Springfield. NOTE: In items 2 & 3 above, it is NOT the DHS/CCR&R eligibility staff's responsibility to follow up with parents to
obtain required documentation. Approved collaboration providers must do this as part of participation in this program.
- Applicants who hold nine (9)-month jobs, e.g., with school districts
These cases will all receive annual/12 months' eligibility. As long as it is known/probable the client will be returning to work in the same job, there is no need to put them on a job search or anything else. They receive 12 months of eligibility. IF the
client loses their job or has some other type of change during the summer or any other time, all CCAP policies and procedures regarding notification of changes will be followed.
- Flexibility in the implementation of CCAP Policy 04.06.01. Change in Information - Parent, which states that parents must report changes within 5 days of the change
There is no provision in this policy for canceling a case if a parent doesn't report a change within the 5-day timeframe. All eligibility staff is directed to be flexible with this timeframe and work with parents to achieve the best outcome for them.
This applies to non-collaboration and collaboration families.
- Confusion about CCAP Policy 06.05.03. Payment Process - Head Start and PreK Collaboration. The intent of this policy is to not penalize child care providers for collaborating, particularly those outside the DHS Child Care Collaboration Program whose
children may be attending a part-day Head Start or PreK program and returning to the child care center or home for the rest of the day. This will be critical for child care providers' participation in the proposed Preschool for All program. A
clarification of the examples in this policy is forthcoming.
- When does a case become a collaboration case and the collaboration program policies available to it?
The particular examples for this issue involved current child care cases with 6-month eligibility periods that become collaboration but then experience a change in their status before their eligibility period ends and they would normally be granted the
annual/12 months eligibility as collaboration.
Eligibility staff should process redeterminations on families upon their changes from non- to collaboration cases, rather than waiting for their existing eligibility periods to end. If the family changes to collaboration within the first sixty (60) days
of their child care enrollment/approval, the case should be redetermined based on the documentation on hand and the case should be granted annual/12 months of eligibility.
- Related to this, is there any way to bridge enrollment times so families that providers know will be in collaboration, but are approved for child care shortly before they can "officially" be called collaboration don't have to have a 6 month
eligibility period first?
Yes, providers can submit families as collaboration if they will be enrolled in an approved collaboration setting within sixty (60) days of their child care application. If, for some reason, the family/child does not become a collaboration case, this
must be reported to eligibility staff and the procedures in CCAP Policy 08.05.02.IV will be followed.
- Cases are being "missed" and processed as non-collaboration when they should be collaboration. This includes new applications as well as redeterminations of current cases.
The Bureau recommends the following strategies to minimize these errors:
- All approved collaboration providers should buy stamps that say "COLLABORATION" in red ink and mark every page of every collaboration child care application form, as well as any other paperwork they submit to CCAP eligibility staff with this stamp.
Stamps can be purchased at minimal cost (generally under $20) from local stationery or office supply stores.
- Approved collaboration providers need to track all of their collaboration families' eligibility periods and communicate with CCAP eligibility staff when a current case is up for redetermination that should change the eligibility period to 12 months.
Sending a monthly list of collaboration families that will be redetermined in the next month to CCAP eligibility staff via fax, mail or email can do this. Collaboration providers should work with their CCAP eligibility specialists to determine the method
that will work best for them.
- Current redetermination paperwork has no place to indicate collaboration cases. Approval letters don't have the number or C indicator on them, so providers don't know until they get the billing form if the children they enrolled have or have not been
processed as collaboration cases.
At this point, collaboration changes are not on the CCAP systems priority list. But if a case is miscoded as non-collaboration that should have been collaboration, the provider can communicate this to CCAP eligibility staff by using a Request for Child
Care Provider Change form (IL444-3455G or GS - Spanish). This form can process moving the case from non-collaboration to collaboration.
- A child enrolls after September but will go to kindergarten the next school year. How many months of eligibility does this collaboration case receive?
If this is an eligible collaboration case, annual/12 months of eligibility should be granted. When the child goes to kindergarten, a Change Progress Report form (IL444-2151A) should be completed and the case cancelled as collaboration.
- How long does a client have to be employed to receive additional job loss grace periods? CCAP Policy 02.04.01 - Grace Periods explains the full extent of the Bureau's current policy on grace periods. Currently, there is no limit on numbers of grace
periods. CCAP eligibility staff should follow this policy as it is written. The only difference for collaboration cases is the substitution of 90 days for the non-collaboration period of 30-days. Please note that this includes III. College Graduation in
02.04.01 - child care eligibility may be extended up to 90 days from the date of graduation so the parent may seek employment in collaboration cases.
- Does IDHS have a written description of its monitoring process that could be shared with providers?
Yes, the CCAP Policy on Monitoring is 07.10.01 and can be found in the online manual.
- On the new certificate/billing forms, can providers add collaboration and non-collaboration children together to calculate their average daily attendance (ADA)?
Yes. Providers can also add site administered and certificate children together, even though they are on separate billing forms.
- How are changes in parent status to be reported?
Changes can initially be reported verbally to CCAP eligibility staff, but all changes must be followed up and reported in writing, per CCAP Policy 04.06.01. All providers should be knowledgeable about this policy so they can inform, guide and support
- Can a job search grace period extend the CCAP eligibility period? How is this processed?
Yes, it can for both collaboration and non-collaboration cases. The only difference is the length of the grace period (90 days for collaboration cases). To process a job search that extends the child care eligibility period, CCAP eligibility staff must
have a redetermination form and mark it "job search."
Because the Bureau has fully integrated the Child Care Collaboration Program into CCAP, future policy questions on it should be addressed to Stacey Splain, Policy Unit Manager, and her staff through the usual CCAP policy question channels. Please
refer to CCAP Policy 07.08.01 - Policy Clarification Request, which give details about what information to include in policy clarification requests and a fax number and e-mail addresses to which they should be sent. For further information, contact the
Bureau's Policy Unit at 217-524-5832. The Bureau's training staff will conduct future training on the Collaboration Program as part of its regularly scheduled CCAP training.